I am having the exact same problem. My wireless network is disabled. I have an MRF-250 about 3 feet from the apple TV. Can't get it any further away than this due to the length of the IR eyes. This is driving me nuts. It makes the Apple TV almost unusable... :(
MX-5000, MX-3000 & MX-850 Remotes + MRF-350 Hitachi 55HDM71 55" Plasma Monitor, Samsung UN46C6500 LED TV, Samsung UN40C6300 LED TV, Yamaha RX-V2700 Receiver, Octava 4x4 HDMI/Cat6 Matrix Switch, etc.